PTAB

IPR2022-00343

Apple Inc v. TelefonakTiebolaget LM ERICsSon

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1. Case Identification

  • Case #: IPR2022-00343
  • Patent #: 9,300,432
  • Filed: February 8, 2022
  • Petitioner(s): Apple Inc.
  • Patent Owner(s): David Hammarwall, et al.
  • Challenged Claims: 1-18

2. Patent Overview

  • Title: Link Quality Estimation and Apparatus in a Telecommunication System
  • Brief Description: The ’432 patent relates to methods and systems for link quality estimation in a wireless communication system to support dynamic link adaptation. The technology involves a sending node (e.g., base station) transmitting a "measurement adjusting parameter" via higher-layer signaling to a receiving node (e.g., user equipment), which then uses the parameter to adjust its channel measurements before reporting channel state information back to the sending node.

3. Grounds for Unpatentability

Ground 1A: Obviousness over 3GPP UMTS Standards - Claims 1-2, 4-7, 9-12, 14-16, and 18 are obvious over TS-25.331 in view of TS-25.214.

  • Prior Art Relied Upon: TS-25.331 (3GPP Technical Specification) and TS-25.214 (3GPP Technical Specification).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination teaches all elements of the challenged claims. The 3GPP standards disclose a User Equipment (UE) receiving a Measurement Power Offset (MPO), which serves as the claimed "measurement adjusting parameter," via dedicated higher-layer Radio Resource Control (RRC) signaling (TS-25.331). The standards further teach that the UE measures properties of a reference channel (the CPICH) and then adjusts this measurement using the MPO to estimate the power of the data channel, as detailed by an explicit equation in TS-25.214. Finally, the UE sends a Channel State Information (CSI) report, containing a Channel Quality Indicator (CQI), back to the network based on this adjusted property.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references because they are companion 3GPP technical specifications for the same UMTS release that explicitly cross-reference each other. TS-25.331 defines the high-level MPO parameter and directly refers the POSITA to TS-25.214 for specific implementation details, making their combined use a natural and necessary step for implementation.
    • Expectation of Success: A POSITA would have a clear expectation of success, as the combination involves using standard-defined parameters exactly as intended by the specifications to achieve the predictable result of improved link adaptation.

Ground 1B: Obviousness over 3GPP Standards and Rank Feedback Art - Claims 3, 5-10, 13, and 15-18 are obvious over TS-25.331, TS-25.214, R1-074426, and Sampath.

  • Prior Art Relied Upon: TS-25.331, TS-25.214, R1-074426 (3GPP Meeting Notes), and Sampath (Patent 8,971,461).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on Ground 1A by adding references that explicitly teach deriving and reporting a rank indicator, as required by claims like claim 3. While the base standards only generally mention rank, R1-074426, a 3GPP document concerning MIMO feedback, explicitly discusses transmitting a "rank suggestion" from the UE. Sampath further provides a concrete method to calculate an effective SNR, use it to select an optimal rank, and then report both the rank and CQI information back to the network.
    • Motivation to Combine: A POSITA implementing the MIMO features generally described in the base TS-25.331/TS-25.214 standards would be motivated to consult related 3GPP documents like R1-074426 and patents like Sampath for specific implementation details on rank feedback, which is a known and critical technique for optimizing MIMO system performance.
    • Expectation of Success: Success was expected because Sampath provides a well-defined algorithm for implementing rank selection within the framework established by the 3GPP standards, bridging the gap between the general standard and a functioning implementation.

Ground 2A: Obviousness over HSDPA CQI References - Claims 1-2, 4-7, 9-12, 14-16, and 18 are obvious over Wintzell in view of Catreux-Erceg.

  • Prior Art Relied Upon: Wintzell (Application # 2005/0003782) and Catreux-Erceg (Patent 7,876,808).
  • Core Argument for this Ground:
    • Prior Art Mapping: The combination discloses a method for determining a CQI in an HSDPA system. Wintzell teaches the general concept of applying a received power offset value to a measured pilot channel SIR to calculate a CQI. Catreux-Erceg provides more specific and compatible details, disclosing the addition of a constant offset (Γ), received from "higher-layers," to a measured CPICH SNR to convert it into an HS-DSCH SNR, which is then used to determine the final CQI value.
    • Motivation to Combine: A POSITA would combine these references as they both address CQI determination in HSDPA systems using compatible approaches. Catreux-Erceg provides specific implementation details, such as an adaptive filter and explicit offset calculation, that a POSITA would naturally seek to implement the more general process described in Wintzell.
    • Expectation of Success: A POSITA would expect success because the combination involves using Catreux-Erceg's more detailed method to realize the system outlined in Wintzell, leading to a predictable and improved CQI calculation process.

Ground 2B: Obviousness over HSDPA CQI and Rank Feedback Art - Claims 3, 5-10, 13, and 15-18 are obvious over Wintzell, Catreux-Erceg, and Sampath.

  • Prior Art Relied Upon: Wintzell (Application # 2005/0003782), Catreux-Erceg (Patent 7,876,808), and Sampath (Patent 8,971,461).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Sampath to the Wintzell/Catreux-Erceg combination to explicitly teach the derivation and reporting of a rank indicator. The base combination of Wintzell and Catreux-Erceg does not detail rank determination for MIMO systems. Sampath fills this gap by teaching a specific method for selecting an optimal rank based on an adjusted SNR and reporting it simultaneously with the CQI.
    • Motivation to Combine: A POSITA implementing the HSDPA system of Wintzell/Catreux-Erceg in a MIMO context—a common scenario—would be motivated to look to a reference like Sampath for a well-defined method of rank selection and reporting, which is a known method to optimize MIMO data rates and efficiency.
    • Expectation of Success: Success was expected because Sampath provides a concrete algorithm for rank selection that is fully compatible with and complementary to the channel quality estimation methods taught by Wintzell and Catreux-Erceg.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) or §325(d) is inappropriate. The petition asserted that no parallel proceedings exist and that none of the prior art combinations applied in the petition were considered in any prior examination or review of the ’432 patent.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-18 of Patent 9,300,432 as unpatentable.